Estate of Watson v. Commissioner
United States Tax Court
Held, where a trust failed to provide for the disposition of the trust corpus after the termination of the trust, a beneficial interest in the trust corpus reverted to the settlor of the trust when the trust terminated and was included in his gross estate under sec. 2033. Held, further, the widow's allowance paid under Mississippi law to the decedent's widow qualifies for the marital deduction provided in sec. 2056(a). Held, further, respondent failed to meet his burden of…
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Held, where a trust failed to provide for the disposition of the trust corpus after the termination of the trust, a beneficial interest in the trust corpus reverted to the settlor of the trust when the trust terminated and was included in his gross estate under sec. 2033. Held, further, the widow's allowance paid under Mississippi law to the decedent's widow qualifies for the marital deduction provided in sec. 2056(a). Held, further, respondent failed to meet his burden of proving that rental proceeds from the decedent's farmland were improperly omitted from the gross estate on the decedent's…
1Opinion of the Court
Estate of Henri P. Watson, Deceased, Henri P. Watson, Jr., Executor, Petitioner v. Commissioner of Internal Revenue, Respondent
Estate of Watson v. Commissioner
Docket No. 31911-85
United States Tax Court
94 T.C. 262; 1990 U.S. Tax Ct. LEXIS 16; 94 T.C. No. 16;
March 1, 1990March 1, 1990, Filed
Decision will be entered under Rule 155.
Held, where a trust failed to provide for the disposition of the trust corpus after the termination of the trust, a beneficial interest in the trust corpus reverted to the settlor of the trust when the trust terminated and was included in his gross estate under sec.…
2Cases cited30 opinions
- Commissioner v. Estate of BoschSupreme Court of the United States · 1967
- Morgan v. CommissionerSupreme Court of the United States · 1940
- Jackson v. United StatesSupreme Court of the United States · 1964
- Ward v. CommissionerUnited States Tax Court · 1986
- Thomas v. BaileyMississippi Supreme Court · 1979
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